Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
On 23 September 2026, SGX RegCo finalised enhanced listing rules requiring Singapore-listed companies to disclose the performance indicators driving executive pay, to publish a dividend policy, and to maintain a visible investor relations presence — all for annual reports covering financial years starting 1 January 2027. The rules are cleaner than their April consultation draft. The board work they require is not trivial and it starts now.
I've sat in enough nomination and remuneration committee meetings to know that the gap between 'we have a remuneration framework' and 'we can explain in plain language what indicators we actually used to set pay this year' is larger than most listed companies will admit. SGX RegCo's 23 September announcement closes that gap with a rule. From financial years beginning on or after 1 January 2027, Singapore-listed issuers must describe in their annual reports the key financial and non-financial performance indicators used to determine executive director and officer remuneration, and explain how those indicators connect to long-term value creation. That's not a disclosure upgrade — it's a governance accountability test dressed as one.
What the rules actually require
There are three distinct requirements. First, the remuneration KPI narrative: companies must describe the specific metrics tied to executive pay, not just the existence of a framework. A board that built its executive compensation structure around revenue growth, total shareholder return, or ESG scorecard targets needs to say which ones and how they were weighted. Second, dividend policy: boards must publish a dividend policy in the annual report. SGX RegCo was deliberate here — there's no mandatory payout commitment. A company that is retaining capital for growth can say so clearly. What it cannot do is say nothing, which many companies currently manage to do. Third, IR presence: all listed issuers must maintain a website with an investor engagement section and publish their IR policy there. This sounds administrative. It is administrative. It also creates a publicly visible record that makes the next investor complaint about access much harder to deflect.
“A board that built its executive compensation structure around revenue growth, total shareholder return, or ESG scorecard targets needs to say which ones and how they were weighted.”
The statistics that explain why this rule exists
SGX RegCo's own data from the consultation: as of May 2026, only 47% of listed companies disclosed the specific financial indicators used to determine executive pay, despite more than 90% incorporating financial metrics into their compensation frameworks somewhere. That means roughly half of Singapore's listed companies have a compensation structure they've never explained. The rule simply requires them to explain it. Tan Boon Gin, CEO of SGX RegCo, put it plainly at the announcement: 'Singapore's equity market is benefiting from a resurgence of investor interest, but this will not last if boards and management do not increase investor engagement and demonstrate greater transparency.' The rule is the follow-through.
What boards should do before the first affected annual report
- Audit the remuneration framework now: can the NRC chair articulate in one paragraph exactly which KPIs drove executive pay for FY2026, with weightings? If not, the disclosure will be thin and the preparation will be rushed.
- Agree a dividend policy with the full board — including the growth-retention rationale if that's the position — before the first affected annual report is drafted.
- Review the company's IR infrastructure: investor engagement webpage, contact mechanism for shareholders, whether the IR policy has ever been written down rather than assumed.
- Confirm first applicability date: the rules apply to annual reports for financial years beginning on or after 1 January 2027, so the first affected reports publish in 2028. That is more time than it sounds only if the board starts the NRC work now.
The rules aren't hard to comply with in the technical sense — the disclosure lengths are modest, the format requirements are principles-based, and early adoption is encouraged. What they require is for a board to have actually done the work that the disclosure describes. That's the uncomfortable part for boards that have been going through remuneration motions rather than running a real NRC process.
Common Questions
When do SGX RegCo's new remuneration and IR disclosure rules take effect?
The new rules apply to annual reports for financial years beginning on or after 1 January 2027, meaning the first batch of compliant annual reports will be published in 2028. SGX RegCo has encouraged early adoption ahead of that date.
What specifically must a Singapore-listed company disclose about executive remuneration under the new rules?
The annual report must describe the key financial and non-financial performance indicators used to determine the remuneration of executive directors and executive officers, and explain how those indicators are aligned with long-term value creation. This goes beyond confirming a framework exists — it requires naming the indicators actually used and their role in pay decisions.
Does the new dividend policy rule require Singapore-listed companies to commit to a specific payout?
No. SGX RegCo explicitly chose not to require a minimum payout commitment. A company that is retaining capital for growth can state that as its policy. The requirement is simply that some dividend policy is disclosed in the annual report, removing the current practice of omitting it entirely.
About the author
Raymond Cheung is a Chartered Actuary, C-suite executive and board adviser with more than 20 years of experience across Asia in risk management, insurance, ESG and corporate governance. He is the CEO of CER Consultancy and an accredited trainer at SMU Academy and the Singapore College of Insurance.